Justia Wyoming Supreme Court Opinion Summaries

David Herrera, Jr. pled guilty to aggravated robbery with a deadly weapon and was sentenced to five to eight years in prison by the district court, which recommended his placement in the Youthful Offender Transition Program (YOTP). Herrera filed a motion for sentence reduction upon nearing completion of the YOTP, asserting that the district court had promised to reduce his sentence if he successfully completed the program.The district court denied Herrera’s motion for sentence reduction without holding a hearing or providing an explanation. Herrera appealed, arguing that the district court abused its discretion and violated his constitutional rights by not honoring the promise made during sentencing.The Wyoming Supreme Court reviewed the case and found that the district court’s oral pronouncement at sentencing, which stated Herrera “will get a sentence reduction” if he completed the YOTP, constituted an express commitment. The court held that the district court abused its discretion by denying the motion for sentence reduction without justification, given the prior commitment. The Supreme Court reversed the district court’s decision and remanded the case for further sentencing proceedings consistent with its opinion. View "Herrera v. The State of Wyoming" on Justia Law

In July 2021, Ryan Schroeder was reported missing, leading to an investigation by the Casper Police Department. Schroeder's last known location was in Denver, and his cell phone records showed communication with Justin Marquez until June 26, 2021. Detectives interviewed Marquez, who admitted to being in Denver but denied picking up Schroeder. Another witness, Jeremiah Cox, last saw Schroeder getting into a maroon SUV with Marquez. Detectives obtained a warrant for Marquez's cell phone records and discovered he owned a maroon Hyundai SUV. A search of the vehicle revealed blood stains and a decomposition odor, leading to further investigation and the discovery of Schroeder's body.The District Court of Natrona County denied Marquez's motion to designate an expert witness after the deadline and two motions to suppress evidence. Marquez argued the search of his vehicle exceeded the warrant's scope and that the warrant contained misrepresentations and omissions. The court found the Hyundai was the intended subject of the warrant and denied the motions to suppress.The Wyoming Supreme Court reviewed the case and affirmed the lower court's decisions. The court held that the district court did not abuse its discretion in denying the late expert witness designation, as Marquez's own conduct caused the delay. The court also found no violation of Marquez's right to compulsory process. Regarding the motions to suppress, the court concluded the search warrant and accompanying affidavits sufficiently described the Hyundai, and there was no reasonable probability of mistakenly searching another premise. The court also found no clear error in the district court's conclusion that Marquez failed to prove intentional or reckless misrepresentation or omission of material information in the affidavits. The Wyoming Supreme Court affirmed the district court's rulings and Marquez's conviction. View "Marquez v. The State of Wyoming" on Justia Law

Rick Holloway and John Hoskin entered into a Commercial Sales Agreement to purchase the UXU Resort Ranch from Hidden Creek Outfitters, LLC. The sale included a special use permit from the U.S.D.A. Forest Service, which required a bridge inspection and load test before transfer. Due to the inspection's delay, the parties postponed closing and placed $200,000 in escrow for bridge-related expenses. After inspections, Park County Title released the escrow funds to Hidden Creek without H&H's consent, despite unresolved bridge issues.The District Court of Park County found that Hidden Creek and H&H each breached the implied covenant of good faith and fair dealing, and Park County Title breached the escrow agreement by releasing funds without H&H's approval. However, the court determined H&H failed to prove actual damages with sufficient certainty, awarding only nominal damages. The court also denied attorney’s fees to all parties.The Supreme Court of Wyoming reviewed the case and affirmed the district court's findings. The court held that H&H did not prove actual damages because the inspections did not conclusively identify necessary or required repairs. The court also upheld the denial of attorney’s fees, finding no abuse of discretion, as both parties bore some fault in the litigation. The Supreme Court denied any attorney’s fees associated with the appeal. View "Holloway v. Hidden Creek Outfitters, LLC" on Justia Law

Samuel Tilden filed a complaint against his neighbor, Linda Jackson, seeking a declaration of an implied easement over Jackson’s property or, alternatively, the establishment of a private road under Wyoming Statute § 24-9-101. Tilden had sold a portion of his property to Jackson in 2010 but retained a 2.64-acre parcel (Subject Property) that included a steep hillside and a flat meadow along the Southfork of the Shoshone River. Tilden and his family had historically accessed the lower portion of the Subject Property via a two-track road on Jackson’s property. After moving out of a cabin he rented from Jackson, Tilden sought legal access to the lower portion of his property.The District Court of Park County granted summary judgment in favor of Jackson on Tilden’s claim to establish a private road, finding that Tilden’s property was not landlocked as it had access to a county road. Following a bench trial, the district court also denied Tilden’s claim for an implied easement, concluding that Tilden’s use of the contested easement was not apparent, obvious, and continuous at the time of severance, and that the easement was not necessary for the enjoyment of his property.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The court held that the district court did not err in granting summary judgment on the private road claim because Tilden’s property had legally enforceable access to a public road, and the necessity for a private road was not established. Additionally, the court upheld the denial of the implied easement, agreeing with the district court’s findings that Tilden’s use of the proposed easement was not apparent, obvious, and continuous at the time of severance, and that the easement was not necessary for the enjoyment of his property. The court emphasized that implied easements should only be recognized when strictly necessary for the use and enjoyment of the dominant estate. View "Tilden v. Jackson" on Justia Law

Gabriel Lee Testerman was found guilty by a jury of one count of first-degree sexual assault. The case involved two victims, CB and CM. CB testified that after meeting Testerman at a bar and later going to his house, she became disoriented after drinking a beverage he made. She alleged that Testerman sexually assaulted her while she was incapacitated. CM, Testerman's former girlfriend, testified that he had previously forced her into non-consensual sexual acts, including using a spreader bar and engaging in anal sex while she was asleep.The District Court of Laramie County admitted evidence of prior bad acts under Wyoming Rule of Evidence 404(b) after a pretrial hearing. Testerman was charged with three counts of first-degree sexual assault, two related to CB and one to CM. The jury acquitted him of the charges related to CB but found him guilty of the charge related to CM. He was sentenced to ten to fifteen years in prison.On appeal to the Supreme Court of Wyoming, Testerman argued that the prosecutor committed misconduct by introducing unnoticed Rule 404(b) evidence and vouching for witnesses during closing arguments. The court reviewed the alleged unnoticed Rule 404(b) evidence and found that five instances were indeed unnoticed but concluded that Testerman was not materially prejudiced by their admission. The court also found that the prosecutor's comments during closing arguments did not constitute improper vouching.The Supreme Court of Wyoming affirmed the lower court's decision, holding that the district court did not abuse its discretion in admitting the evidence and that Testerman was not deprived of a fair trial due to prosecutorial misconduct or cumulative error. View "Testerman v. State" on Justia Law

Richard Hanson was a passenger in a vehicle stopped for missing license plates. During a consent search of the vehicle, law enforcement discovered a firearm and drug paraphernalia with residue inside a backpack. Hanson was charged with and convicted of being a felon knowingly in possession of a firearm and third offense possession of a controlled substance. On appeal, Hanson argued that the search of the vehicle was unlawful and that the district court erred in denying his motion to suppress the evidence collected from the backpack. He also contended that the district court abused its discretion by denying his motion to suppress evidence as a discovery sanction.The District Court of Lincoln County denied Hanson’s motion to suppress evidence, finding that the search was lawful and that Hanson’s consent to the search was voluntary. The court also denied Hanson’s second motion to suppress evidence disclosed by the State after the discovery deadline, concluding that the delay was not due to bad faith and that Hanson was not unduly prejudiced by the late disclosure. Hanson was subsequently found guilty on both counts and sentenced to imprisonment.The Supreme Court of Wyoming reviewed the case and affirmed the district court’s decisions. The court held that the traffic stop and subsequent search were lawful, as the officer’s questioning and request to search were reasonable under the circumstances. The court also found that Hanson’s consent to the search was voluntary, considering the totality of the circumstances. Additionally, the court determined that the district court did not abuse its discretion in denying Hanson’s motion to suppress the late-disclosed evidence, as the delay was not intentional and did not unduly prejudice Hanson. The Supreme Court of Wyoming affirmed the district court’s rulings and Hanson’s convictions. View "Hanson v. The State of Wyoming" on Justia Law

David Martorano (Father) and Melissa Mazzei (Mother) divorced in 2020 and share two children, BM and EM. The initial divorce decree provided for joint legal and physical custody and required Father to pay $1,800 per month in child support. In 2022, Mother sought to modify child custody and support. Both parties submitted confidential financial affidavits (CFAs) in late 2022, with Father reporting a net monthly income of $46,150 and Mother reporting $6,354. In October 2023, they updated their CFAs, with Father reporting a significant reduction in income to -$5,455 per month, citing decreased income from his employment and losses from his LLC, WY Knot Charters.The District Court of Natrona County calculated child support based on the figures from the 2022 CFAs, ordering Father to pay $7,830.94 per month and $90,464 in arrears. Father filed a motion for relief from judgment under W.R.C.P. 60, requesting the court to use his 2023 CFA and to recalculate arrears from October 2022 instead of August 2022. The district court granted the motion in part, recalculating arrears from October 2022 but maintaining the child support amount based on the 2022 CFA.The Supreme Court of Wyoming reviewed the case and affirmed the district court's decision. The court found no clerical mistake or oversight in the district court's reliance on the 2022 CFA and determined that changing the income figures would result in a substantive modification of the judgment, which is not permissible under W.R.C.P. 60(a). The court also held that the district court did not abuse its discretion in denying relief under W.R.C.P. 60(b), as the accuracy of the 2023 CFA was disputed, and the proper avenue for challenging the district court's discretion was a direct appeal, not a W.R.C.P. 60 motion. View "Martorano v. Mazzei" on Justia Law

Bryant Ross Montoya was convicted of felony property destruction after he intentionally rammed his truck into another vehicle driven by Samuel Kremer. The incident stemmed from a prior altercation between the two men, who were former friends. On the day of the incident, their accounts differed, with Montoya claiming self-defense after Kremer allegedly hit his truck first, while Kremer and an independent witness, Vincent Sandberg, reported that Montoya was the aggressor.The District Court of Laramie County instructed the jury on self-defense, using instructions that addressed the use of deadly force. Montoya did not object to these instructions during the trial. The jury found Montoya guilty, and he was sentenced to a prison term of two to four years, suspended in favor of three years of probation. Montoya appealed, arguing that the district court erred by instructing the jury on self-defense using deadly force rather than non-deadly force.The Wyoming Supreme Court reviewed the case and found that although the record contained the allegedly erroneous instructions, Montoya did not demonstrate material prejudice. The court noted that the State's argument focused on Montoya being the aggressor, supported by testimony from Kremer and Sandberg. The court concluded that there was no reasonable probability that the jury verdict would have been different without the alleged error in the instructions. Consequently, the court affirmed Montoya's conviction. View "Montoya v. The State of Wyoming" on Justia Law

Bankers Standard Insurance Company (Bankers) filed a lawsuit against JTEC, Inc. (JTEC), a professional engineering firm, alleging that JTEC negligently designed a water mechanical system for a housing development in Jackson, Wyoming. The design flaw allegedly caused a water filter housing to fail, resulting in significant water damage to a home insured by Bankers. The design plans, which included the alleged defect, were revised multiple times, with the final set submitted on May 31, 2018.The United States Court of Appeals for the Tenth Circuit reviewed the case and certified a question to the Wyoming Supreme Court regarding the interpretation of Wyo. Stat. Ann. § 1-3-107. The district court had granted summary judgment in favor of JTEC, determining that the statute of limitations barred Bankers' claim. The district court concluded that the relevant date for the statute of limitations was May 31, 2018, the last day JTEC provided professional services.The Wyoming Supreme Court reviewed the certified question to determine when a professional’s act, error, or omission occurred under Wyo. Stat. Ann. § 1-3-107. The Court held that the absence of contractual privity is not relevant in determining when the statute of limitations attaches in a tort action. The statute of limitations attaches to the design that was the legal cause of the alleged injuries, meaning the act, error, or omission that was a substantial factor in bringing about the plaintiffs’ injuries.The Court concluded that the statute of limitations in § 1-3-107 attaches to the design that was used by the plumber to install the water entry detail at the Grossmans’ residence. However, the Court could not determine which set of engineering plans were used based on the facts presented. Therefore, the case was remanded for further proceedings to establish which design was the legal cause of the alleged injuries. View "Bankers Standard Insurance Company v. JTEC, Inc." on Justia Law

In 2016, a divorce decree awarded Eric Van Genderen Sr. (Father) custody of his child, EVG, with visitation rights for Ekaterina Nicholaevna Pokrovskaya (Mother). In 2022, Mother sought to modify her visitation rights, alleging Father was alienating EVG from her and not adhering to the visitation terms. The district court found a material change in circumstances and modified the visitation schedule to include a graduated plan starting with supervised visits.The District Court of Teton County granted Mother’s request for modification, establishing a graduated visitation schedule due to Father’s refusal to allow meaningful contact between Mother and EVG. The court found it in EVG’s best interests to amend the visitation schedule, starting with supervised visits and potentially leading to unsupervised visits. Father was ordered to pay for Mother’s travel expenses during the transition period.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decision. The court held that the district court had jurisdiction over the matter and that Mother’s appeal was timely. The court found no abuse of discretion in the district court’s detailed and clear visitation schedule, which considered the best interests of EVG, including the quality of the parent-child relationship, the ability of each parent to provide care, and the geographic distance between the parents. The court also upheld the allocation of travel costs to Mother after the transition period, noting that the district court’s decision was reasonable and within its discretion. The Wyoming Supreme Court concluded that the district court’s findings were supported by the evidence and affirmed the modified visitation order. View "Pokrovskaya v. Van Genderen" on Justia Law